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CAMPBELL v. COMMISSIONER

Docket No. 21209-07.

134 T.C. 20 (2010)

ALBERT D. CAMPBELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 21, 2010.

Attorney(s) appearing for the Case

Bradley J. Davis and Loan B. Kennedy , for petitioner.

Miriam C. Dillard , for respondent.

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for taxable year 2003 of $3,044,000, an accuracy-related penalty pursuant to section 6662(a) of $608,800, and a delinquency addition to tax pursuant to section 6651(a)(1) of $151,955.50.1 We must decide the following issues: (1) Whether a "qui tam" settlement payment is taxable income to petitioner; (2) whether petitioner has substantiated that he...

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